Understanding OSHA's 1910 120 (HAZWOPER) Requirements

OSHA is not involved in regulating hazardous waste. However, they are concerned about the safety of workers who must handle, work with, or even work near areas where hazardous waste is present.

The OSHA 1910.120 standards, covering employees working with hazardous waste, are known as HAZWOPER. These standards apply to five types of operations:

1. Clean-up operations required by a governmental body at uncontrolled hazardous waste sites;
2. Clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA);
3. Voluntary clean-up operations at a site recognized by a governmental body as an uncontrolled hazardous waste site;
4. Operations involving hazardous wastes conducted at treatment, storage, and disposal facilities regulated by 40 CFR 264 and 265;
5. Emergency response operations related to the releases of, or the substantial threats of releases of, hazardous substances.

The following is a broad overview of the worker protections and requirements included in OSHA 1910.120.

Required Safety and Health Program

OSHA 1910.120 requires a written safety and health program covering employees who are involved in hazardous waste operations. Although it must address hazardous waste, it does not need to repeat anything already included in existing standard operating procedures. It must include:

• A description of the site organizational structure;
• A comprehensive work plan covering work related to hazardous waste;
• A site-specific safety and health plan, including the use of engineering controls, work practices and PPE to protect workers;
• A safety and health training program;
• A medical surveillance program;
• The facility's standard operating procedures for safety and health;
• A description of the interface between the general safety program and hazardous waste specific activities.

Required Site Characterization and Analysis

Before work begins, sites potentially containing hazardous waste must be evaluated to identify the specific site hazards, the characteristics of the hazardous waste, and the safety and health control procedures needed to protect employees from those hazards.

Required Site Control Program

A site control program defines how employees will be protected. It is initially written during the planning stages. As the work progresses it is modified as necessary. At a minimum the site control program must include:

• A site map;
• Identification of site work zones;
• Establishment of a buddy system;
• Establish the means of site communications, including an alert system for emergencies;
• Establish standard operating procedures and safe work practices;
• Identify the nearest medical assistance.

Required Training

All employees who may potentially be exposed to hazardous substances, health hazards, or safety hazards, must be trained before they start work. The training must:

• Identify those at the site who are responsible for site safety and health;
• Identify the safety and health hazards present on the site;
• Train workers in using personal protective equipment;
• Train workers in how to use work practices that minimize risks;
• Train workers in the safe use of engineering controls and equipment on the site;
• Train workers concerning the site's medical surveillance requirements, including how to recognize the symptoms and signs which might indicate overexposure to hazards.

Required Medical Surveillance

 A medical surveillance program must be in-place, and it must cover following all employees who:

• May be exposed to hazardous substances or health hazards;
• Wear a respirator for a total of 30 days or more during a 12 month period;
• Wear a respirator as required by 1910.134;
• Who are injured, become ill, or develop signs or symptoms as a result of a possible overexposure involving hazardous substances;
• Are members of a HAZMAT team.

Required Medical Examinations and Consultations

Employers are required by OSHA 1910.120 to provide free medical examinations to all employees prior to the start of a work assignment involving hazardous waste. In addition, a free medical exam must be provided at least every 12 months, as well as when the employee stops working in an area where there is hazardous waste (if they've not had a medical exam in the past six months).

A medical exam must also be provided if an employee has been exposed to a hazardous substance, or should they develop the signs or symptoms of exposure to a hazardous substance.

Engineering Controls, Work Practices, and PPE

Engineering controls, work practices, PPE, or a combination of these are used to protect employees from hazards, and must be described in the site's safety and health plan. However OSHA 1910.120 specifically excludes a common administrative control, rotation of workers, from being used, unless there is no other option for protecting workers.

Required Monitoring

Monitoring is required to verify that control measures are effective and that workers are not being exposed to hazards at a level that exceeds the permissible exposure limits (PELs). If OSHA has not established a PEL for a certain substance, then published exposure limits must be used.

Requirements for Handling Drums and Containers

Working at a site that contains hazardous materials often involves working with drums and other types of containers. In many cases some or all of these containers are buried. OSHA has specific requirements for handling and transporting drums, containers, contaminated soil, liquids, and residues.

The following is a short list of some of the requirements:

• Labeling of hazardous material containers is important. OSHA 1910.120 requires workers to assume that any unlabeled containers hold hazardous materials.
• All containers used for hazardous materials must meet OSHA, DOT, and EPA requirements, and be inspected prior to being moved. In addition, movement of containers must be minimized.
• Spill containment equipment and absorbents must be readily available. In addition, there must be a written spill containment plan.
• Fire control equipment must be available, and ready to use.

Decontamination Requirements

OSHA 1910.120 requires that there be decontamination procedures for all aspects decontamination, including accidental exposures. Decontamination operations must be documented in written procedures that also identify the location of decontamination equipment and supplies. In addition, the following must be provided:

• All needed PPE;
• Employees available who are trained in and authorized to do decontamination;
• Whatever is necessary to meet laundry needs and requirements;
• Shower and change rooms. 

Emergency Response Plan

There must be a written emergency response plan in place before starting any work involving hazardous waste. The plan must anticipated potential emergencies and address the following:

• Pre-emergency planning;
• Roles and duties of personnel;
• An emergency alerting system and response procedures;
• Lines of communication and authority;
• Emergency recognition and prevention;
• PPE and emergency equipment;
• Establishment of safe distances and places of refuge;
• Site security and control during the emergency;
• Evacuation routes and procedures;
• Decontamination procedures (not already included in the site safety and health plan);
• Provisions for emergency medical treatment and first aid;
• Evaluation of the response and follow-up.

Incorporating New Technology

The employer is required to be aware of new technology, and to introduce new technology that provides better protection for employees working with or near hazardous waste.

OSHA 1910.120

OSHA's goal with 1910.120 is to ensure that no one is injured, or has their health affected, as a result of working with or near hazardous waste. Many of the dangers associated with hazardous waste are unseen, and protecting workers requires complete adherence to all of 19190.120's requirements. This has just been an overview of those requirements. Complete familiarity with OSHA 1910.120 is necessary before doing any work involving hazardous waste.